Spring 1999, Vol. 62, No. 1

We have, each of us, a log in our eyes that prevents us from seeing into another person's heart, from understanding the reasons for another person's actions, and, therefore, from formulating a just judgment of those actions.

An increase in the claims of ineffective representation by counsel has accompanied the recent surge of litigation. As more and more litigants are called upon to respond to such claims, the appellate courts have been forced to delineate a basic threshold of competence. Not only is the standard by which counsel is deemed effective or ineffective constantly changing, but also decisions of the higher courts have been devoid of a guideline by which future problems may be anticipated. This review of case law traces the evolution of both state and federal decisions during the past fifteen years in an attempt to demonstrate the manner in which such claims are resolved.